Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Customs Broker due diligence requires prescribed KYC, not detecting misdeclarations discoverable only through physical examination, defeating licence ...
E-filing system failure permits exclusion of affected time in insolvency appeals, preventing tribunal technology defects from defeating timely filings...
Final settlement orders under section 245D(4) cover statutory deductions disclosed in the settlement application, including a section 80IB(10) housing-project deduction. Chapter XIX-A permits departure from that finality only when the Settlement Commission declares its order void for fraud or misrepresentation. It does not preserve a parallel power for the Assessing Officer to reopen, under sections 147 and 148, deduction issues already covered by the final settlement. Where the prescribed recourse to challenge the settlement order has been rejected and attained finality, reassessment of that deduction is unsustainable.
Final settlement orders under section 245D(4) cover statutory deductions disclosed in the settlement application, including a section 80IB(10) housing-project deduction. Chapter XIX-A permits departure from that finality only when the Settlement Commission declares its order void for fraud or misrepresentation. It does not preserve a parallel power for the Assessing Officer to reopen, under sections 147 and 148, deduction issues already covered by the final settlement. Where the prescribed recourse to challenge the settlement order has been rejected and attained finality, reassessment of that deduction is unsustainable.
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